New Deadlines, New €20 Million Funding: EUDI Feedback Deadline Approaching as Implementation Demands Accelerate

The deadline for providing feedback on the European Union Digital Identity Wallet (EUDI) initiative is September 9. The Implementing Acts on the European Commission’s website details the standards for certification, supported protocols and interfaces, integrity and core functionalities, trust framework, and identification data and attestation. The European Commission (EC) invites citizens and organizations to comment on the technical specifications provided, signifying a key opportunity to shape the technology as eIDAS 2.0 continues the journey to adoption. The open-source code and the latest version of the Architecture and Reference Framework (ARF) are publicly available via GitHub. Openness is built into the ethos, with EUDI being available to “anyone who wants to use it.”

The EC has invested €46 million into pilot programs, with an additional €20 million round of funding accompanying the implementation of The EU Digital Identity Framework Regulation in May. The regulation mandates that EU Member States provide EUDI wallets to all residents by 2026. The pilots, launched in April 2023, are testing the wallet among 360 participating organizations across 26 Member States, testing various use cases across governmental services and documents, finance and payments, telecommunications, health, electronic signatures, and travel. The use cases suggested are diverse and will continue to grow.

Member States are each at varying levels of progression, but this phase of feedback implementation and mandatory availability will mean a solidification of the technology and regulation, which will push states less advanced in the process to keep up. Widespread international adoption is key in fully realizing the EUDI vision, so ensuring progress happens across the board is essential. Allowing open dialogue with feedback initiatives helps to prevent a mandated approach from isolated actors, ensuring everyone can operate in the eventual ecosystem.

This initiative has not been without its challenges and criticisms—while there is an emphasis on an “opt-in” model, with users able to “choose and keep track of their identity, data and certificates,” it is unclear how practicable this would be if widespread adoption is achieved and the numerous use cases are fully adopted. Some have expressed criticism over the breadth of power that would be achieved with this initiative, citing surveillance concerns. The window is closing on taking these criticisms onboard, and both existing and new pilots will need to carefully consider not just technological trust, but the trust of citizens who will be expected to allow their details to be managed by these schemes.

For organizations seeking to implement this technology, clarity is key in the message to end users. Regulation, and especially technology-focused regulation, is challenging for non-specialists to fully understand, so explaining exactly what a specific implementation of the digital wallet does succinctly and addressing concerns in laymen’s terms is important. This is particularly vital given the diversity of use cases. While the fundamental point of the wallet remains the same—a reliable, convenient method of identification and document linking, acting as a single point of trust—user opinion may vary by application, unless messaging is clear and consistent.

Finally, a balance must be struck between a healthy, diverse ecosystem and a fractured one. Pilots have emphasized international collaboration, but have also been focused on “the usual suspects” of countries with strong tech industries, and it is unclear whether other Member States are in danger of failing to meet the 2026 deadline.